Madigan v. Graco Inc.

Background

Sophia Madigan worked for Graco as a machinist. After learning she was pregnant in January 2023, she gave Graco medical notes requesting that she avoid lead and other potentially harmful chemicals, loud noise, and lifting more than 15 pounds. The notes also requested quieter office work and eight-hour shifts.

Madigan and Graco agreed that she could not continue working as a machinist while following those restrictions. Graco temporarily assigned her to reprogram meters at its Anoka office and later assigned her office work at its Riverside facility in Minneapolis. The work avoided the restrictions, although Madigan objected that Anoka was farther from her home and that Graco would not provide five eight-hour shifts per week. Graco permitted three eight-hour shifts and counted the remaining missed hours against her leave. After childbirth, Madigan took two weeks of paid leave and about thirteen weeks of unpaid leave. She resigned on January 19, 2024, citing medical reasons.

Madigan asserted five causes of action: violation of the Minnesota Parenting Leave Act, violation of Minnesota’s pregnancy-accommodations statute, pregnancy discrimination under the Minnesota Human Rights Act, pregnancy discrimination under Title VII of the Civil Rights Act, and retaliation under the Family and Medical Leave Act. Graco moved for summary judgment, which asks whether the evidence could allow a reasonable jury to rule for the opposing party.

Minnesota Parenting Leave Act and Family and Medical Leave Act

The court granted summary judgment on Madigan’s Minnesota Parenting Leave Act claim. The court held that Graco did not deny her the statutory leave. It also held that Madigan’s theory that Graco forced her to use Family and Medical Leave Act leave was not ripe because she was never denied leave later, and that she received the protected leave required after childbirth. The court further concluded that Graco was not required to provide five eight-hour shifts because Madigan’s medical notes required eight-hour shifts but did not recommend five workdays each week.

The court also granted summary judgment on the Family and Medical Leave Act claim. It found no viable entitlement theory because Graco provided the required leave. It found no retaliation theory because Madigan did not show that she opposed a practice prohibited by that law. Her discrimination theory also failed because the challenged actions—including providing three eight-hour shifts, warning her about leave exhaustion, and counting intermittent leave—did not create a triable issue of unlawful discrimination or a causal connection to her use of protected leave.

Minnesota Pregnancy-Accommodations Statute

The court granted summary judgment on this claim. The statute requires reasonable accommodations for pregnancy-related health conditions unless the accommodation would create an undue hardship, but it does not require an employer to create a new or additional position. The court found that Graco provided temporary work in Anoka and then Minneapolis that accommodated Madigan’s restrictions. Graco also allowed eight-hour shifts and resolved the identified lifting and possible noise issues.

The court rejected Madigan’s arguments that Graco had to provide five eight-hour shifts, provide additional work without counting the remaining hours against Family and Medical Leave Act leave, or treat her initial medical notes as mandatory rather than requesting restrictions. The court concluded that the statute did not require Graco to create additional work or provide leave without counting it against another applicable leave program.

Pregnancy Discrimination Claims

The court granted summary judgment on the Minnesota Human Rights Act and Title VII pregnancy-discrimination claims. Applying the burden-shifting framework used when there is no direct evidence of discrimination, the court assumed that Madigan was in a protected group and qualified for her machinist position. It held, however, that she had not shown an adverse employment action supported by an inference of pregnancy discrimination.

Madigan identified the denial of full-time hours, being placed on leave, and not receiving twelve weeks of paid leave. The court found that the first two theories largely repeated her accommodation and leave arguments and did not establish an adverse employment action. Even assuming the failure to pay was adverse, Madigan identified no similarly situated nonpregnant employees who received better treatment. The court also found that the machinists Madigan identified as comparators had materially different restrictions and circumstances.

Disposition

Judge Eric C. Tostrud ordered that Graco’s motion for summary judgment was granted. The court dismissed Madigan’s complaint with prejudice and directed that judgment be entered accordingly. The court also discussed two incorrect case citations in Madigan’s opposition brief but chose not to order further proceedings under Federal Rule of Civil Procedure 11.